WEEE Compliance Declaration (Directive 2002/96/EC)
The WEEE (Waste of Electrical and Electronic Equipment) directive establishes minimum requirements for handling waste of electrical equipment, which has to be accomplished country by country via national laws. The goal of the directive and the corresponding national laws is the environmentally conscious disposal of waste of electrical and electronic equipment used privately or in industry, focussing primarily on household appliances and equipment (§1). The question remaining open is to which extent components of industrial controls are subject to the scope of this directive, e.g. relays, contactors, sensors, monitoring and control instruments, control devices, PLC components, inverters or electrical drives.
According to article 2, the directive encompasses electrical and electronic equipment in the categories listed in annex 1A, provided that the equipment concerned is not part of another type of equipment that does not fall within the scope of this directive. Such equipment, namely large scale stationary industrial tools, is listed in category 6 of annex 1A and is hence explicitly excluded from the scope of the directive. According to Orgalime (Liaison Group of the European Mechanical, Electrical, Electronic and Metalworking Industries), large-scale stationary tools are, "Machines or systems consisting of a combination of equipment and/or components, each of which is manufactured to be used in industry only, permanently fixed and installed by professionals at a given place in industrial machinery or in an industrial building to perform a specific task. They are not intended to be placed on the market as a single functional or commercial unit. Equipment that is part of another type of equipment is not considered to be a finished product."
As parts of a fixed installation, e.g. industrial monitoring, controls and drive components in this respect are exempted as they are part of and form a functional unit of the machine. Hence they are not subject to the WEEE directive.
Moreover, tool machinery, machine systems and the related components and control units are not comparable to those of private households with respect to waste disposal at the end of their life, neither in regard to their constituion nor the quantity in which they are produced. Finally, these goods have not been nor will be disposed of in municipal waste.
Summarizing, components of monitoring and controls technology as well as electrical drives being used in large-scale stationary industrial tools are generally not subject to the WEEE directive or the respective national laws. Hence registering our company with national registration authorities, e.g. EAR in Germany, is not necessary for these products. Nevertheless, we are keeping an eye on how this directive and the corresponding national laws develop.